Lawsuit: Pending PhillinDeBlanc v. The Crown, Case 12 (Mag. Ct., 2025)

[PhillinDeBlanc]

IN THE HONOURABLE MAGISTRATE OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION

Case No.: 12


BETWEEN:


PHILLINDEBLANC
(Operating Sanctum Exchange Corporation)
Plaintiff


v.


THE CROWN OF THE KINGDOM OF ALEXANDRIA
Defendant


COMPLAINT


I. JURISDICTIONAL STATEMENT AND VENUE

1. This Court has jurisdiction over this suit pursuant to §14 of the Constitution of the Kingdom of Alexandria which vests judicial power in the courts to interpret and administer the law.
2. The Magistrate Court is the proper venue for this suit as §16 of the Constitution of the Kingdom of Alexandria grants this court jurisdiction over all civil and criminal matters.

II. PARTIES

3. PhillinDeBlanc (hereinafter "Plaintiff") is an individual seeking to register Sanctum Exchange Corporation, intended to be the largest commodities exchange in Alexandria. Sanctum Exchange Corporation is currently operating but requires formal registration to pursue further business development, including public listing.​

4. The Crown of the Kingdom of Alexandria (hereinafter "Defendant" or "the Crown") is the legal body recognized for proper service of suits alleging constitutional violations and ultra vires actions by its Ministries. See Reallmza v. The Crown, Case 1 (Ch. 2025).​

III. FACTS

5. The Parliament of Alexandria enacted the Legal Entity Act (A.P.020) (hereinafter "LEA"), on May 6th, 2025, which provides for the formation and regulation of legal entities, including Corporations.​

6. Section 7 of the LEA outlines the mandatory process for the formation of a Corporation:​

• Section 7(3)(a): "The Incorporators shall file a Certificate of Incorporation."
• Section 7(3)(c): "The Ministry of Trade and Finance shall verify the Certificate of Incorporation for compliance within 5 days."
• Section 7(3)(d): "The Ministry of Trade and Finance shall be liable to pay $50 every begun day exceeding this limit to the Incorporators."
• Section 7(3)(e) provides limited, specific reasons for extending this time limit ("complexity of the Certificate of Incorporation" or "an exceedingly high amount of filings"), neither of which has been cited by the Ministry of Trade and Finance (hereinafter "MoTF") in the current matter.

7. On or around May 29th, Omegabiebel, the Minister of Trade and Finance, announced via official channels a "PAUSE ON LEGAL ENTITY REGISTRATION," stating: "The MOTF is still setting up the infrastructure needed for the registration of legal entities so until further notice the registration of legal entities is CLOSED." (Evidence of this announcement is available and will be produced.)​

8. The Plaintiff, on behalf of Sanctum Exchange Corporation, had either submitted or was prepared to submit a Certificate of Incorporation for registration in accordance with Section 7 of the LEA.​

9. Due to the MoTF's announced pause, the Plaintiff is unable to complete the legal registration of Sanctum Exchange Corporation.​

10. Section 12 of the LEA, titled "Power of the MOTF," enumerates the powers granted to the MoTF. These powers include maintaining the Company Registry (Sec 12.1), creating rules and regulations essential for enforcing the act (Sec 12.2), disbanding inactive sole proprietorships (Sec 12.3), and executing forced dissolutions of incorporated entities (Sec 12.4).​

11. The LEA does not explicitly or implicitly grant the MoTF the power to unilaterally suspend or pause the entire process of new legal entity registration as mandated by Section 7 and other provisions of the Act.​

IV. CLAIMS FOR RELIEF

​

​

COUNT I: ULTRA VIRES ACTION BY THE MINISTRY OF TRADE AND FINANCE
12. Plaintiff realleges and incorporates paragraphs 1 through 11 as if fully set forth herein.
13. The MoTF is a creature of statute and may only exercise powers expressly or implicitly granted to it by Parliament through legislation such as the LEA.
14. The general pause on legal entity registrations announced by the MoTF is not an enumerated power under Section 12 of the LEA, nor can it be reasonably implied from the powers granted, particularly the power to create rules for "enforcing this act" which presumes the Act is in operation.
15. The MoTF's duty to verify Certificates of Incorporation within 5 days, as mandated by Section 7(3)(c) of the LEA, is a positive obligation. A failure to provide resources or "set up infrastructure" to meet this statutory duty does not grant the MoTF the authority to suspend this duty entirely.
16. Therefore, the MoTF's pause on legal entity registrations is an act ultra vires, exceeding its lawful authority.


COUNT II: FRUSTRATION OF STATUTORY RIGHTS AND ECONOMIC HARM
17. Plaintiff realleges and incorporates paragraphs 1 through 16 as if fully set forth herein.
18. The LEA, particularly Section 7, creates a statutory pathway and an expectation for individuals and businesses like the Plaintiff's to form and register Corporations.
19. The MoTF's unlawful pause directly prevents the Plaintiff from exercising his statutory right to seek registration for Sanctum Exchange Corporation.
20. As a direct and proximate result of this inability to register, Sanctum Exchange Corporation has suffered and continues to suffer significant economic harm. Specifically:
a. Sanctum Exchange Corporation is unable to proceed with a planned Initial Public Offering (IPO) to raise approximately £10,000 in capital, as legal registration is a prerequisite for listing on the New Hamilton Stock Exchange.
b. The inability to raise capital impedes the growth, operational capacity, and market development of Sanctum Exchange Corporation, which has an estimated current market value of approximately £50,000.
c. The delay causes ongoing financial loss, missed opportunities, and damages the business's momentum and reputation.


V. PRAYER FOR RELIEF


WHEREFORE, Plaintiff respectfully requests that this Honourable Court:


A. Declare that the Ministry of Trade and Finance’s announced pause on legal entity registration is ultra vires and unlawful.
B. Issue a mandatory injunction compelling the Ministry of Trade and Finance to immediately cease its pause on legal entity registrations and to process submitted Certificates of Incorporation, including that of Sanctum Exchange Corporation, in accordance with the timelines and procedures set forth in the Legal Entity Act.
C. Award damages to the Plaintiff for the economic harm suffered as a result of the unlawful pause, in an amount to be proven at trial.
D. Award costs of this suit.
E. Grant such further and other relief as this Court deems just and proper.


RESPECTFULLY SUBMITTED,











PhillinDeBlanc
Plaintiff


Dated: 06/14/25

 

[PhillinDeBlanc]

IN THE HONOURABLE MAGISTRATE OF THE KINGDOM OF ALEXANDRIA

Case No.: 12

BETWEEN:

PHILLINDEBLANC
(Operating Sanctum Exchange Corporation)
Applicant/Plaintiff

v.

THE CROWN OF THE KINGDOM OF ALEXANDRIA
Respondent/Defendant

The Applicant, PhillinDeBlanc, hereby respectfully moves this Honourable Court for an Order granting urgent interim relief pending the final determination of this matter, and alleges as follows:

1. Prima Facie Case: The Applicant has a strong prima facie case that the Ministry of Trade and Finance (MoTF) has acted ultra vires by imposing a general pause on legal entity registrations. As detailed in the main Complaint and supported by the Legal Entity Act (LEA), particularly Sections 7 and 12, the MoTF lacks the statutory authority for such a blanket suspension. Section 7 of the LEA imposes a mandatory duty on the MoTF to process applications for incorporation within a specified timeframe, offering limited exceptions not applicable here.
2. Irreparable Harm: The Applicant and Sanctum Exchange Corporation will suffer immediate and irreparable harm if the interim relief is not granted.
   a. Sanctum Exchange Corporation is actively operating and poised for significant growth, which is currently stalled by the inability to register.
   b. Specifically, the pause prevents Sanctum Exchange Corporation from proceeding with a time-sensitive Initial Public Offering (IPO) valued at approximately £10,000 on the New Hamilton Stock Exchange. This opportunity to raise crucial capital may be lost or significantly diminished by delay.
   c. The inability to secure this funding directly impacts the corporation's ability to expand operations, compete effectively, and realize its market potential (current estimated value ~ £50,000). Such lost opportunities and stunted growth are difficult, if not impossible, to quantify and compensate fully with monetary damages at a later date.
   d. Continued delay erodes business momentum and may damage the reputation of Sanctum Exchange Corporation among potential investors and market participants.
3. Balance of Convenience: The balance of convenience overwhelmingly favors the Applicant. The harm to the Applicant and Sanctum Exchange Corporation from the continued unlawful pause is substantial and ongoing. Conversely, the inconvenience to the MoTF in complying with its statutory duty to process registrations is a burden legislatively imposed and anticipated by the LEA itself (including provisions for reasonable extensions under specific circumstances not invoked here, and penalties for non-compliance with verification timelines). The public interest also lies in the lawful and efficient administration of business registrations.
4. Urgency: The matter is urgent due to the ongoing financial harm and the time-sensitive nature of the planned IPO. Each day the unlawful pause continues to exacerbate the damage to Sanctum Exchange Corporation's financial prospects and strategic objectives.

THEREFORE, THE APPLICANT PRAYS FOR AN URGENT INTERIM ORDER:

A. Directing the Ministry of Trade and Finance to immediately lift its general pause on legal entity registrations.
B. Directing the Ministry of Trade and Finance to forthwith accept and process the submission of the Certificate of Incorporation for Sanctum Exchange Corporation, and other similarly situated entities, in accordance with the procedures and timelines mandated by the Legal Entity Act, pending the final resolution of this Complaint.
C. Such further and other relief as this Honourable Court deems just and equitable in the circumstances.


PhillinDeBlanc

RESPECTFULLY SUBMITTED TO THE COURT.

Dated: 06/14/25

 

[Pepecuu]

IN THE MAGISTRATE'S COURT OF ALEXANDRIA
WRIT OF SUMMONS​

The Crown's legal counsel are required to appear before the Magistrate's Court in the case of PhillinDeBlanc v. The Crown, Case 12 (Mag. Ct., 2025).

Failure to appear within 72 hours of this summons will result in a default judgment based on the known facts of the case.

Both parties should make themselves aware of the Court Rules and Procedures (General and Specific), including the option of an in-game trial should both parties request one.

 

[Pepecuu]

IN THE MAGISTRATES COURT OF THE KINGDOM OF ALEXANDRIA
Ruling on the Writ of Urgent Interim Relief by the Claimant​

In evaluating the Claimant's Writ of Urgent Interim Relief, the Court shall be guided by the precedent set out in ColonelKai v. Crown, Case 8 (Ch. 2025), where the Chancery noted that the power to grant such writs must be exercised with “an abundance of caution,” and only when the harm is of a kind that cannot be undone or meaningfully redressed at final hearing.

The Court notes several key issues that prevent the granting of this Writ.

First, the harm alleged, namely a delay in accessing public capital markets, does not rise to the level of irreparable harm. The company’s IPO is prospective and contingent on multiple external factors. There is no submitted evidence of binding investor commitments, underwriting agreements, or regulatory approvals that would render the delay definitively destructive to the business.

Second, the Court observes that the Legal Entity Act, the statute under which the claims of this case are founded, does not unambiguously prohibit temporary delays of the kind that is currently imposed. The lack of clarity in the statute, combined with the limited evidence submitted by the Claimant to back their arguments, prevents the Court from finding a strong enough prima facie case to justify the Urgent Interim Relief sought.

Third, as was cautioned in ColonelKai v. Crown, Case 8 (Ch. 2025), granting interim relief in such cases may “come dangerously close to ruling on the merits for the Claimant.” That risk is present here. To direct the MoTF to lift its administrative pause would be to prematurely imply that such a policy is unlawful, a decision that must only be made after all arguments and evidence are presented within the proceedings of this case.

Finally, the pause in registrations is a temporary measure affecting all prospective registrants equally and does not appear targeted or discriminatory. There is no evidence that the Claimant is being singled out or that the public interest will be harmed more by delay than by a possible judicial interference in administrative affairs.

Accordingly, this Court therefore declines the Writ for Urgent Interim Relief by the Claimant. This shall not be construed as a ruling on the merits of this case, but merely on the merits of the Entreaty for Emergency Relief filed in conjunction with the Claimant's initial case filing.

 

[Ibney0]

The Crown is present, your honor.

 

[Pepecuu]

The Crown is present, your honor.

The Defendant now has 48 hours to provide their answer to the complaint.

If necessary, please request an extension and state the amount of extra time required, as well as the reason for the extension.

 

[Ibney0]

IN THE HONOURABLE MAGISTRATE OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION
Case No.: 12

phillindeblanc
v.
The Crown of the Kingdom of Alexandria

ANSWER TO COMPLAINT

1. Admitted
2. Admitted
3. Admitted
4. Admitted
5. Admitted
6. Admitted
7. Admitted
8. Admitted
9. Denied
10. Admitted
11. Denied
12. Admitted
13. Admitted
14. Denied
15. Denied
16. Denied
17. Admitted
18. Admitted
19. Denied
20. Denied

AFFIRMATIVE DEFENSES:

1. Act of Mod - The defendant alleges that the inability of the Ministry of Trade and Finance to properly incorporate companies is a direct result of the moderation staff. A plugin error, which the MOTF has dutifully pursued a resolution too, prevents further movement by the MOTF towards a solution. Similar to an "act of god," defendant asserts that because of forces so out of their control they are unable to perform with their statutory duty and can not be held liable for this action.

Respectfully submitted,

Joseph Ibney0
Minister of Justice
Kingdom of Alexandria

 

[Pepecuu]

Discovery is now open for a period of 72 hours. Extensions may be granted if mutually agreed upon by both parties.

 

[PhillinDeBlanc]

IN THE MAGISTRATES COURT OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION – CASE 12
PLAINTIFF'S WITNESS LIST

The Plaintiff hereby designates the following witnesses for testimony:

1. Omegabiebel – Minister of Trade & Finance
2. Ibney0 – Minister of Justice (for adverse admissions)
3. Staff – Server admin / plugin developer
4. PhillinDeBlanc – Plaintiff

Respectfully submitted,
PhillinDeBlanc
Date: 17 June 2025

 

[PhillinDeBlanc]

IN THE MAGISTRATES COURT OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION – CASE 12
ENTREATY TO COMPEL PRODUCTION


The Plaintiff respectfully moves, pursuant to Court Rules (Discovery § Request for Discovery, Opposing Party Movement), for an Order compelling the Crown to produce the documents and information listed within 24 hours of the Court’s ruling.


Grounds: These materials are directly relevant to the Crown’s affirmative defence (“Act of Mod”) and to the Plaintiff’s ultra vires claim. Without them, the Plaintiff cannot fairly prepare for trial or test the veracity of the Defendant's assertions.


Requests for Production:

1. All internal Ministry of Trade & Finance or Crown communications (including but not limited to Discord messages, forum private messages, and emails) created between 6 May 2025 and the present date regarding the decision to “pause” legal entity registrations.

2. All server logs, error reports, or bug reports concerning the alleged plugin error that is preventing or impeding the incorporation of legal entities.

3. All communications with server moderators or developers regarding the fixing of the alleged plugin error, including dates when fixes were first requested, status updates, and any provided timelines for resolution.

4. A list of all Certificates of Incorporation submitted to the Ministry of Trade & Finance since 6 May 2025, including the date of submission and their current processing status (e.g., pending, approved, rejected).


Interrogatories (to be answered by the Crown under oath):

1. State the precise statutory power or legal authority upon which the Minister of Trade & Finance relies for the authority to "pause" the processing of Certificates of Incorporation mandated by the Legal Entity Act.

2. Describe in detail the nature of the “plugin error” cited as the reason for the pause. The description must include: (a) the date the error was first discovered by the Crown, (b) the specific functions the error impairs, (c) all steps taken to date to remedy the error, and (d) the current expected date for the error to be fully resolved.

3. Identify the person or persons who have been assigned primary responsibility for verifying and processing Certificates of Incorporation manually during the period the plugin is non-functional.

4. If no one has been assigned for manual processing, explain in detail why manual processing of Certificates of Incorporation is impossible or impracticable.

5. Admit or deny that the Plaintiff, on behalf of Sanctum Exchange, delivered or attempted to deliver a compliant Certificate of Incorporation to the Ministry of Trade & Finance on or after 6 May 2025.


Respectfully submitted,

PhillinDeBlanc

Date: 17 June 2025